Effective date: 2 November 2026

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1. Who we are and what this covers. This policy explains how LLC “DEVELOPMENT SOLUTIONS” (EDRPOU 45625073; "we", "GreenHub") processes personal data of users of the GreenHub mobile app and of apps published on the GreenHub platform under a management company's brand (the "App"), as well as the administrator web panel and the website greenhub.ua (together, the "Services").

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2. Roles. The GreenHub platform serves management companies of residential complexes and hotels. Your management company decides who is registered as a resident, which doors, cameras and services you can use and which data about you it keeps; it is the controller of your personal data under Ukrainian data protection law and the GDPR. We process data on its behalf as processor and are responsible for the platform's security. For the data needed to run the account itself (sign-in contacts, app settings, technical logs) we act as controller.

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3. What we process and why (data — source — purpose).

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• Name, email, phone number, premises (building, section, apartment) — your management company at registration; you when updating your profile — account creation, one-time-code sign-in, contact with your management company

• One-time sign-in codes — generated by us — sign-in confirmation; sent to your email or phone

• Access identifiers: card/fob numbers, vehicle plate numbers, QR passes, guest passes — your management company or you in the App — opening doors, gates and barriers; guest access

• Face photo — only if you enable face recognition yourself — you — opening doors by face; processed on platform servers and on your building's equipment; can be disabled and deleted in the App

• Access log (door, time, which identifier) — building equipment — building security; you see your own entries in the App

• Requests, messages to the concierge and management company, attached photos — you — handling your requests

• Bookings, bills and billing documents — your management company and you — building services; no payments are taken in the App

• Push notification tokens, device model, OS and App version — your device — delivering notifications; compatibility

• Technical logs and crash reports (no message content) — your device and our servers — App stability and security

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We do not collect location, do not use advertising identifiers, show no ads, do not sell data and do no profiling. Building camera streams are shown in the App in real time and are not recorded by the App.

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4. Device features. Camera — for photos attached to requests and, if you choose, your face photo; photo library — for attachments; notifications — for push. Each permission is requested when needed and can be revoked in device settings. Microphone and location are not used in this version.

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5. Who receives data. Your management company, within its role as controller. Our providers, processing data under our instructions and data-protection agreements: Amazon Web Services (hosting and backups, Ireland region; email and SMS delivery of sign-in codes), Google Firebase / Apple Push Notification service (push delivery; only the device token is passed), Sentry (crash reports, EU servers), Expo (app build service; receives no personal data). Public authorities — only on a lawful request. There are no other transfers.

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6. Where data is stored. On servers in the European Union (AWS, Ireland). Transfers outside the EU/Ukraine happen only to providers with an adequate level of protection (standard contractual clauses).

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7. Retention. Account data — while the account exists; technical logs — up to 90 days; access log and request history — per your management company's policy and legal requirements; backups — up to 35 days (daily) and 400 days (monthly), then deleted automatically.

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8. Security. Transport encryption (TLS), encrypted backups, role-based staff access, administrator action logging, one-time codes instead of passwords for residents.

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9. Your rights. Access, rectification, erasure, restriction, objection, portability, withdrawal of consent (for face recognition — in the App at any time), and complaint to the Ukrainian Parliament Commissioner for Human Rights or the supervisory authority in your country. Requests about data held by your management company are forwarded to it; requests about the account we fulfil ourselves within 30 days. Contact: support@greenhub.ua. Account deletion: Profile → Delete account, or see instructions (greenhub.ua/delete-account).

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10. Children. The App is intended for adult residents. We do not knowingly collect data of persons under 18; if a management company has registered such a person, tell us and the account will be deleted.

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11. Changes. Material changes are announced in the App. The current version's date is shown at the top.

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12. Contact. LLC “DEVELOPMENT SOLUTIONS”, support@greenhub.ua.